Superior Beverage Company of Marysville, Inc. v. Commissioner of Internal Revenue, Superior Beverage Company of Redding and Red Bluff, Inc. v. Commissioner of Internal Revenue, Superior Beverage Company of Chico, Inc. v. Commissioner of Internal Revenue

525 F.2d 186 75-2 USTC P 9808 SUPERIOR BEVERAGE COMPANY OF MARYSVILLE, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. SUPERIOR BEVERAGE COMPANY OF REDDING AND RED BLUFF, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. SUPERIOR BEVERAGE COMPANY OF CHICO, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Nos. 73-1309 to 73-1311. United States Court of Appeals, Ninth Circuit. Oct. 20, 1975. Bayley Kohlmeier (argued), San Francisco, Cal., for petitioner-appellant. Richard Farber, Atty. (argued), U. S. Dept. of Justice, Tax Div., Washington, D. C., for respondent-appellee. OPINION Before CHAMBERS and MERRILL, Circuit Judges, and PALMIERI, * District Judge. CHAMBERS, Circuit Judge: 1 This is an appeal from a decision of the Tax Court reported with a detailed factual description at 58 T.C. 918 (1972) assessing deficiencies in the income tax of each of the appellant corporations for the years 1966, 1967, and 1968. We reverse. 2 As a general rule under 26 U.S.C. § 11 (d), every corporation is entitled to a yearly surtax exemption of $25,000. If a company is a member of a…